Consumer Privacy Notice

In this notice, JRL Capital Management and the above listed subsidiaries, non-related affiliates, or advisor DBAs are referred to collectively as “JRL Affiliates”, “us”, or “our” and individually as “JRL”

JRL Affiliates strongly believe in protecting the confidentiality and security of information we collect about individuals and entities it does business with. This notice describes the privacy policy followed by each JRL Affiliate regarding:

• how we treat information we receive (“Information”) about individuals or entities who apply for or obtain our products or services (“Customers”); and
• the third parties with whom we may share this Information.

INFORMATION WE COLLECT

“Nonpublic Personal Information” is nonpublic information about the Customers that we obtain in connection with providing a financial product or service to the Customer for personal, family, or household purposes.

We collect Nonpublic Personal Information about Customers from the following sources:

• Information provided to us directly by a Customer on an application or other form in connection with our products or services. This may include but not be limited to: name, address, social security number, assets, and income.
• Information about a Customer’s transactions with us, our affiliates, or others, such as account balance, payment history, parties to a transaction, credit/debit card usage, and insurance policy coverage and premiums.

INFORMATION DISCLOSED TO THIRD PARTIES

We do not disclose any Nonpublic Personal Information about our Customers or former Customers to anyone, except as permitted by law or required by regulatory agencies.

INFORMATION WE PROVIDE TO OUR SERVICE PROVIDERS AND JOINT MARKETING PARTNERS

We may disclose all of the Information we collect, as described above, to nonaffiliated companies that perform services on our behalf, or to other financial institutions related to a Customer’s transactions. For example, Information may be disclosed to others to enable them to provide business services for us, such as helping us to evaluate requests for products or services, performing general administrative activities for us, and assisting us in processing a transaction requested by a Customer.

DISCLOSURE FOR INFORMATION ABOUT FORMER CUSTOMERS

If a Customer decides to close an account or otherwise becomes an inactive Customer, we will continue to follow privacy practices described in this notice with respect to such Customer.

PROTECTING CONFIDENTIALITY AND SECURITY

We treat Information in a confidential manner. Our employees are required to protect the confidentiality of Information. Employees may access Information only when there is an appropriate reason to do so, such as administer or offer our products and services. Employees are subject to disciplinary rules if they do not comply with our polices. We also maintain physical, electronic, and procedural safeguards to protect Information; these safeguards comply with all applicable laws. Our commitment ensures that we provide privacy and safety for our Customers.

DISCLOSURE

JRL does not carry Errors & Omission or Malpractice Insurance.

CONTACTING FINRA

Customers can contact FINRA at FINRA and then bring up the link to “Investor Help” for available information. You may also access a list of FINRA departments and phone numbers through the website at the “Contact Us” link. For Public Disclosure Information you may use the website or call 1-800-289-9999.